cross-posted from Alliance for the Defeat of Citizenship Taxation
NB: While ADCT respects ACA’s positions and appreciates their lobbying efforts, this post in no way serves as an endorsement of their submission regarding RBT.
It bears repeating that no group approached Congress during the tax reform process and specifically requested RBT. Many chose to support RO’s effort (TTFI) assuming it more likely to succeed given Congress was clearly intent upon changing corporations to a territorial model.
ACA’s approach to RBT has been described by some as CBT with a carve-out (for those who are already compliant). It does not address the issues of Accidental Americans; becoming compliant for the express purpose of renunciation, etc.
TAX REFORM BILL AND AMERICANS ABROAD: WHAT HAPPENED? WHAT’S NEXT?

by Charles M Bruce
ACA’s Legal Counsel and Of Counsel to Bonnard Lawson-Lausanne
with contributions from Jonathan Lachowitz, Chairman, ACA, Marylouise Serrato,
Executive Director, ACA, and Jacqueline Bugnion, Former Director, ACA.
On the day President Trump signed the The Tax Cuts and Jobs Act (TCJA) , Mr. Bruce issued this letter (found on the ACA website).
EXCERPTS:
What happened?
Changes in the basic rules for Americans abroad were not made.
There are strong indications that Congress will soon return to the subject of tax law changes to make corrections in what was done and to address issues that were postponed. A couple of days ago Chairman Brady said, “I’m going to recommend that we do have some form of tax reconciliation in future budgets because there are still areas of the tax code I think . . . can be improved, including retirement savings, education, and streamlining,” Brady said. “And we had a number of good ideas from our members we weren’t able to accommodate. Plus, I think we’ll have to continue to modify the international code over time.”
What has not changed?
- The basic foreign earned income and housing cost amount exclusion (FEIE) has not changed
- The 3.8% net investment income tax to fund Medicare and The Affordable Care Act, remains in place and continues to apply in a way that, for Americans abroad, exposes them to double taxation because they are not allowed to credit foreign taxes against it.
There are some serious problems.

Hi everyone,
Last night I saw a statement of Brady published in Politico on his latest on tax reform. The last sentences is truly encouraging. The article is below. I understand “letting them pay taxes only where they live” to indicate RBT. Since the Ways and Means has announced that it will publish its legislative draft next week, the language is most likely already determined. There have been several proposals for tax reform of Americans abroad from various organisations. Let’s all get behind whatever Congress comes up with and show a united front. This is a one chance in a lifetime to improve the situation of Americans abroad. Please activate your networks in this sense.
Best,
Jackie Bugnion
This was at the end of a POLITICO e-mail, sent 25 October.
He[Brady] said the committee is considering an issue dear to U.S. citizens living abroad — letting them pay taxes only where they live — though no decision has been made.
Some additional e-mail trail, I will not disclose sender:
Just listening to Ari Fleischer on TV about the tax reform bill and he said something that I wasn’t aware of, but some of you might be: He said that once the bill comes out of W&M Committee it goes directly to a floor vote. There are no floor amendments or changes permitted. Thought this is something to look for.